The Lead April 17, 2025 - LeadingAge Illinois

From the Desk of Angela Schnepf, President and CEO
LeadingAge Illinois Bi-Weekly Member Call
OIG to Audit SNF Compliance with Coverage of Part D Drugs, Hospice Enrollment Oversight Needs
LCMS Seeks Feedback on Deregulation of the Medicare Program
CMS Releases the FY 2026 Hospice Wage Index, Payment Rate Update, and Quality Reporting Program Proposed Rule
Minor Updates to the I-9 Form and E-Verify
Dr. Oz Confirmed as CMS Administrator
Upcoming IDPH Webinars
Senators Call for GAO Investigation of Assisted Living
Off-Cycle Medicare Revalidations Delayed
CMS Releases SNF PPS Proposed Rule for FY2026
Upcoming COE-NF Trainings
HUD Sets 2025 Income Limits for Housing Assistance
CMS Releases Updated List of Unacceptable Hospice Principal Diagnosis Codes
Ask the Expert

From the Desk of Angela Schnepf, President and CEO

We wanted to make sure you were aware that the Nursing Home Medicare Revalidation Deadline Extended to August 1. CMS has announced it on April 17, extending the deadline, from May 1 to August 1, for off-cycle revalidation for all Medicare-certified nursing homes to be completed.

Kindest Regards,

Angela

LeadingAge Illinois Bi-Weekly Member Call

We are excited to invite you to our biweekly member meeting, open to all members! This is a great opportunity to stay informed on the latest legislative developments and education updates, as well as engage with our featured guest speakers.

Mark your calendars!

Every other Monday from 10:00 – 11:00 AM

Next one April 28th

Meeting Highlights:

Legislative Updates: Learn about the most recent legislative changes that may impact our community from our Public Policy Team.
Education Updates: Stay up-to-date with the latest education offerings.
Featured Guests: Special guests will join us to share their expertise and insights on key topics.

This event is free and open to all members—we encourage you to join, participate, and connect with fellow members and LeadingAge Illinois staff.

We look forward to seeing you on Zoom!

OIG to Audit SNF Compliance with Coverage of Part D Drugs, Hospice Enrollment Oversight Needs

The Health and Human Services (HHS) Office of the Inspector General (OIG) updated its work plan to include a new audit in 2025 examining skilled nursing homes and whether they complied with federal requirements under consolidated billing to cover the cost for Part D drugs for enrollees on a Part A SNF stay. A prior audit of these practices found that $465.1 million of beneficiaries on a SNF Part A stay were erroneously covered under the Part D program. OIG notes that SNF Part A payments are to “cover most services, including drugs and biologicals, furnished by a SNF for use in the care and treatment of enrollees.” Therefore, Medicare Part D should not pay for prescription drugs related to SNF care because those drug costs are to be covered by the Medicare prospective payment system (PPS) for the Part A stay.

The new audit also includes a hospice workplan item to look at trends and patterns of new Medicare hospice enrollments that may indicate further oversight is needed. As providers know, federal requirements indicate that hospices must be certified by the Centers for Medicare & Medicaid (CMS) and be licensed as required by State and local law. Medicare also requires that hospices meet the Conditions of Participation (CoPs) to receive payment. OIG plans to identify trends, patterns, and key comparisons that indicate potential vulnerabilities related to new Medicare hospice provider enrollments. The data brief may help CMS evaluate the need for additional monitoring and program integrity efforts to ensure that hospices meet all the requirements. OIG expects the report to be released in Fiscal Year (FY) 2026. The new audit was announced in April 2025 and is projected to be completed this year.

CMS Seeks Feedback on Deregulation of the Medicare Program

The Centers for Medicare & Medicaid Services (CMS) released an RFI webpage to comply with President Trump’s Executive Order (EO) 14192 “Unleashing Prosperity Through Deregulation” which tasks the Administration to significantly reduce the private expenditures required to comply with Federal Regulations to secure America’s economic prosperity and national security and the highest possible quality of life for each citizen. CMS is seeking input on approaches and opportunities to streamline regulations and reduce burdens on providers, suppliers, beneficiaries, Medicare Advantage and Part D plans, and other stakeholders participating in the Medicare program.

CMS is seeking specific information from healthcare providers, researchers, stakeholders, health and drug plans, and other members of the public to inform the development and implementation of strategies to support the goals of the aforementioned EO. CMS invites responses on the following topics:

Streamline Regulatory Requirements

Are there existing regulatory requirements (including those issued through regulations but also rules, memoranda, administrative orders, guidance documents, or policy statements), that could be waived, modified, or streamlined to reduce administrative burdens without compromising patient safety or the integrity of the Medicare program.
Which specific Medicare administrative processes or quality and data reporting requirements create the most significant burdens for providers?
Are there specific Medicare administrative processes, quality, or data reporting requirements, that could be automated or simplified to reduce the administrative burden on providers?

Opportunities to Reduce Administrative Burden of Reporting and Documentation

What changes can be made to simplify Medicare reporting and documentation requirements without affecting program integrity?
Are there opportunities to reduce the frequency or complexity of reporting for Medicare providers?
Are there documentation or reporting requirements within the Medicare program that are overly complex or redundant? If so, which ones? Please provide the specific Office of Management and Budget (OMB) Control Number or CMS form number.

Identification of Duplicative Requirements

Which specific Medicare requirements or processes do you consider duplicative, either within the program itself, or with other healthcare programs (including Medicaid, private insurance, and sate or local requirements)?
How can cross-agency collaboration be enhanced to reduce duplicative efforts in auditing, reporting, or compliance monitoring?
How can Medicare better align its requirements with best practices and industry standards without imposing additional regulatory requirements, particularly in areas such as telemedicine, transparency, digital health, and integrated care systems?

Additional Recommendations

Any other suggestions or recommendations for deregulating or reducing the administrative burden on health care providers and suppliers that participate in the Medicare program.

The RFI can be completed by answering the questions on this website. LeadingAge Illinois/Iowa will be developing tools and resources to aid nursing home members in completing the RFI soon.

CMS Releases the FY 2026 Hospice Wage Index, Payment Rate Update, and Quality Reporting Program Proposed Rule

On April 11, the Centers for Medicare & Medicaid Services (CMS) issued the Fiscal Year (FY) 2026 Hospice Wage Index, Payment Rate Update, and Hospice Quality Reporting Program Requirements (QRP) proposed rule which is scheduled to be published in the Federal Register on April 30, 2025. Comments are due on the proposed rule approximately June 10, 2025. The following provisions were included in the proposed rule.

Proposed Wage Index & Payment:

The proposed hospice wage index applicable for FY 2026 (October 1, 2025, through September 30, 2026) is available on the CMS website at https://www.cms.gov/medicare/payment/fee-for-service-providers/hospice/hospice-regulations-and-notices.

The proposed payment rebases and revises the IPPS market basket to reflect the 2023 base year and includes the following rates:

Routine Home Care (days 1-60) $230.33
Routine Home Care (days 61+) $181.51
Continuous Home Care Rull Rate $1,665.23 or $69.38 per hour
Inpatient Respite Care $531.60
General Inpatient Care $1,197.40

Hospice providers that do not submit the Quality Reporting Program (QRP) data can find proposed rates on page 23 of the proposed rule.

The proposed hospice cap amount for the FY 2026 cap year is $35,292.51 which is equal to the FY 2025 cap amount plus the updated percentage of 2.4%.

Proposed Regulation Changes:

The proposed rule includes some regulatory revisions as outlined below.

Upon admission to hospice services, the attending physician and the hospice medical director must certify that the patient has a life expectancy of six months or less. In subsequent 90- or 60-day periods of hospice care, only the hospice medical director or the physician member of the interdisciplinary group (IDG) recertifies that the patient is terminally ill based on their clinical judgement. CMS is proposing to include “or the physician member of the hospice interdisciplinary group” to indicate that in addition to the medical director or physician designee, he physician member of the hospice IDG may also determine admission to hospice care to better align consistent language across hospice regulations and policies.
To clear up confusion in documentation practices and requirements for face-to-face encounters, regulations are proposed to be revised including that the physician, or nurse practitioner (NP) who performs the face-to-face encounter attest that the encounter occurred and must include the signature of the physician or NP who conducted the face-to-face encounter with the date it was signed. Additionally, the attestation, its accompanying signature and the date, must be a separate and distinct section of, or an addendum to, the recertification form and must be clearly titled.

Hospice Quality Reporting Program (HQRP):

CMS provided updates on the Hospice Outcomes and Patient Evaluation (HOPE) tool including Training and Education at https://www.cms.gov/medicare/quality/hospice/hqrp-training-and-education-library. This course includes five interactive exercises to help providers understand and apply the content with additional detailed comprehensive training to follow and be available on the page linked above. CMS continues to collect HOPE data and will determine public reporting measures that will be implemented no earlier than FY 2028.

Update on the Transition to iQIES:

Beginning on October 1, 2025, the new CMS submission and reporting system will begin accepting data from HOPE along with provider reported. The QIES system will stop accepting HIS records for hospice admissions and discharges that occurred prior to October 1, 2025, including any corrections, on February 15, 2026.

RFIs:

CMS is seeking feedback on the following topics.

Advancing Digital Quality Measurement (dQM. CMS is considering opportunities to advance Fast Healthcare Interoperability Resources (FHIR)-based reporting of patient assessment data in settings that were not eligible to participate in the Medicare Electronic Health Record (E.H.R.) Incentive Program (now known as the Medicare Promoting Interoperability Program), while acknowledging that such providers may be at different levels of health IT adoption and readiness. Specifically, assessing the feasibility of using the FHIR standard for the submission of HOPE data. The objective is to explore how hospices typically integrate technologies with varying complexity into existing systems and how this affects hospice workflows, challenges or opportunities that may arise during integration and support needed to complete and submit the HOPE in ways that protect and enhance care delivery. Additionally, CMS is seeking feedback on the current state of Hospice IT use. A complete list of questions can be found beginning on page 42 of the proposed rule.
Interoperability Quality Measures focusing on readiness and capabilities for interoperability in Hospice settings.
Patient Well-Being includes a comprehensive approach that emphasizes person-centered care by promoting the well-being of hospice patients which includes tools and/or measures that can assess overall health, happiness, and satisfaction at the end of life, which could include aspects of emotional well-being, social connections, purpose, fulfillment, and self-care work.
Nutrition including feedback on tools and frameworks that promote health, safe eating habits, exercise, nutrition, and activity appropriate for optimal end-of-life care.

Minor Updates to the I-9 Form and E-Verify

On April 2, the U.S. Citizenship and Immigration Services posted a new I-9 form and Employment Eligibility Verification to align with statutory language along with updating the Privacy notice. The revised I-9 form includes an edition date of 1.20.25 and expires 5.31.27 or the 8.1.23 edition that is valid until 7.31.26. However, employers using the form with the expiration date of 7.31.26 will need to update their form on 8.1.26 until the expiration date of 5.31.27 with the latest form.

Key updates to the I-9 form include:

Renaming the fourth checkbox in Section 1 to “An alien authorized to work”
Revising the descriptions of two List B documents in the Lists of Acceptable Documents
Adding appropriate statutory language and a revised Department of Homeland Security (DHS) Privacy Notice to the Instructions.

Beginning on April 3, E-Verify and E-Verify+ will have updated the citizenship status selection during case creation to reflect the statutory language. The selection “A noncitizen authorized to work”, will be updated to “An alien authorized to work”.

Employers should note:

If an employee attests on Form I-9 as “A noncitizen authorized to work,” the employer must select “An alien authorized to work” in E-Verify
E-Verify cases will display “An alien authorized to work,” which employees and employers may continue to see “A noncitizen authorized to work” on Form I-9, depending on the form edition being used.
E-Verify+ participants will see the updated 1.20.25 edition date and 5.31.27 expiration date reflected in the form I-9NG

Additionally, E-Verify users creating cases through Web Services applications will see the employee status attestation automatically updated to “An alien authorized to work” – even if the WS application submits “A noncitizen authorized to work” if the employee selected citizenship status number four on Form I-9.

This change does not affect the current Interface Control Agreement (ICA) version 31.1, which already provides the necessary guidance for Web Services developers. WS developers should update their platforms to transmit “An alien authorized to work” instead of “A noncitizen authorized to work” as soon as possible.

Revised copies are linked below:

You can find these and other information on the U.S. Citizenship and Immigration Services website.

Dr. Oz Confirmed as CMS Administrator

The Senate confirmed Dr. Mehmet Oz as the Centers for Medicare & Medicaid Services Administrator on April 3, 2025. Senators voted along party lines, 53 to 47 to confirm Dr. Oz’s nomination. You can read more about the March confirmation hearing before the Senate Finance Committee here, who advanced the nomination to the full Senate on March 25.

On April 10, Dr. Oz issued a press release about his first week as CMS Administrator including his vision for the future. He noted that the future of CMS includes efforts to Make America Healthy Again with curiosity, courage, competence and compassion along with modernizing Medicare, Marketplaces, and Medicaid. These focuses include efforts to:

Empower Americans with personalized solutions so they can better manage their health and navigate the health care system including implementing the executive order on price transparency.
Equipping providers with better information about those they serve, holding them accountable for health outcomes rather than unnecessary paperwork.
Identifying and eliminating fraud, waste, and abuse to stop unscrupulous people stealing from vulnerable patients and taxpayers.
Shifting the paradigm from focusing on sickness to one that fosters prevention, wellness, and chronic disease management.

Upcoming IDPH Webinars

The Illinois Department of Public Health announced the following upcoming webinars. Registration is required and attendance is limited. If you’re unable to attend, email Michael.moore@illinois.gov as the webinar will be recorded and can be distributed following the event.

Identified Offenders Program on April 23 from 1-2 p.m.
Tuberculosis Infection Control in LTC Facilities on May 16 from 1 – 2 p.m.
Intermediate and Skilled Nursing Staffing Rules on May 21 from 1 – 2 p.m.
Antimicrobial Stewardship on May 30 from 1 – 2 p.m.
NHSN Requirements for LTCFs on June 13 from 1 – 2 p.m.
LLCS Network Training on June 18 from 1 – 2 p.m.
Vaccine Storage and Handling on June 27 from 1 – 2 p.m.

Senators Call for GAO Investigation of Assisted Living

Three senators called on the Government Accountability Office (GAO) to investigate assisted living to determine if federal oversight should be implemented. A report released in 2018 by GAO indicated that state oversight of critical incidents in assisted living was poor.

The GAO found that the Centers for Medicare and Medicaid Services may not be aware of occurrences of evictions, medication errors or other critical incidents because of differences in state definitions. The report recommended that CMS increase oversight and state reporting of deficiencies and critical incidents to better understand the wellbeing of Medicaid Participants residing in assisted living. In a letter dated March 31, from Senators Elizabeth Warren (D-MA), Ron Wyden (D-OR), and Kirsten Gillibrand (D-NY) ask GAO Comptroller General Eugene Dodaro for updates to the 2018 report.

The letter outlines the lack of a federal regulatory framework for assisted living and state variation in regulatory administration. The letter goes on to ask GAO to investigate specifics about critical incidents and determine whether there is need for additional federal oversight of assisted living. Any updates from GAO will take some time; in the meanwhile, the current administration is not expected to take measures for federal oversight of assisted living. However, the calling on GAO to investigate perpetuates some of the negative perceptions our field continues to battle. The senators’ request follows a January 2024 hearing of the Senate Special Committee on Aging Hearing,

“Assisted Living Facilities: Understanding Long-Term Care Options for Older Adults.” “We support state systems that provide complete transparency about complaints, their resolution, and quality ratings so that consumers have all the knowledge they need before they move into a residential setting. We do not believe it would be effective to attempt imposing a federal regulation or reporting structure on a set of services that evolved to respond to state and local consumer interest in supportive care – but not nursing care – and a distaste for nursing homes,” LeadingAge said in testimony submitted to the January 2024 hearing.

Off-Cycle Medicare Revalidations Delayed

The Centers for Medicare & Medicaid Services (CMS) posted in their weekly Medicare Learning Network (MLN) newsletter on April 17, 2025, that the deadline to submit SNF revalidation information on ownership, managerial and related party information has been extended until August 1, 2025.

LeadingAge compiled a quick reference guide and members may check out the recording of a February 11 webinar Understanding the New Off-Cycle Nursing Facility Revalidation.

LeadingAge Illinois/Iowa also hosted a webinar on the Off-Cycle Revalidation process, particularly around the additional disclosable parties’ requirements. If you’re interested in reviewing this free webinar, please email Michelle Rybicki for access.

CMS Releases SNF PPS Proposed Rule for FY2026

On April 11, the Centers for Medicare & Medicaid Services (CMS) Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities (SNF) and Updates to the Quality Reporting Program (QRP) for Federal Fiscal Year (FY) 2026 was released in the Federal Register and scheduled to be published on April 30, 2025. Comments on the proposed rule will be due within 60 days of the public inspection date in the Federal Register or approximately June 10, 2025. Due to several Requests For Information (RFI) LeadingAge Iowa is planning a strategy to aid members in providing comments on the proposed rule and RFI.

Payment:

The proposed rule includes an increase of 2.8% in Medicare SNF payments or $997 million in aggregate payments to SNFs in FY 2026. This includes a 3% market basket update, a 0.6% forecast error adjustment, and reduced by a 0.8% productivity adjustment totaling a 2.8% increase.

Consolidated Billing:

In the consolidated billing section of the proposed rule, CMS is requesting feedback on HCPCS codes that should be excluded from consolidated billing including new HCPCS codes related to the five service categories already excluded (chemotherapy items, chemotherapy administration services, radioisotope services, customized prosthetic devices, and blood clotting factors) as well as additional HCPCS codes that should be considered.

CMS is proposing to add, remove, or change assignments to ICD-10 codes including the following which are being changed to “Return to Provider” if used as primary diagnosis codes:

Type 1 Diabetes Mellitus (E10.A1; E10.A2; E10.9)
Hypoglycemia (E16.A1; E16.A2; E16.A3; E16.0; E16.1; E16.2; E16.3; E16.4; E16.8; and E16.9)
Obesity (E66.811; E66.812; E66.89; E66.01; E66.09; E66.1; E66.3; and E66.9)
Anorexia Nervosa, Restricting Type (F50.010)
Anorexia Nervosa, Binge Eating/Purging Type (F50.020 and F50.021)
Bulimia Nervosa (F50.21 and F50.22)
Binge Eating Disorder (F50.810 and F50.81)
Pica and Rumination Disorder (F50.83; F50.84; F98.21; and F98.3)
Serotonin Syndrome (G90.81)

SNF QRP:

CMS is not proposing to adopt any new measures in the SNF QRP and would like to remove four items previously adopted as data elements under the Social Determinants of Health (SDOH) category based on the burden that providers will have collecting data beginning with the FY2027 SNF QRP. Thes measures were slated to be included on the Minimum Data Set (MDS) beginning October 1, 2025.

Living situation (proposed R0310)
Two items for food (proposed R0320A and R0320 B)
Utilities (proposed R0330)

Additionally, CMS is proposing to amend the reconsideration policy and process and are seeking public comment on the following:

Future measure concepts for the SNF QRP
Potential revisions to the data submission deadlines for assessment data collected for the SNF QRP
Advancing digital quality measurement in SNFs

CMS notes that they are turning their focus towards how data and associated recommendations exchanged can improve care coordination, efficiency, reduction in errors, and resident experience. As health information technology advances and the interoperability of data becomes more standardized, the burden to collect and share data will become less burdensome, allowing for better outcomes for SNF residents.

Finally, CMS included a proposal to amend the reconsideration request process which currently allows a SNF to request reconsideration of an initial determination that SNF QRP data was not submitted timely based on extenuating circumstances within 30 days. CMS would like to amend the policy by removing the term extenuating circumstances as it is not clearly defined in the code and replace it with the term extraordinary circumstances as this term is consistently used and defined. CMS is also proposing to modify the basis by which a SNF may request an extension to file a reconsideration (past the 30 days generally allowed) and incorporate explanations regarding the meaning of extraordinary circumstances in the Extraordinary Circumstance Exception and Extension (ECE) policy. CMS is also proposing to allow SNFs to request reconsideration of a noncompliance determination within 30 calendar days of the date of the written notification of noncompliance. The request must be submitted via email and include the CCN, business name, business address, contact information of the CEO or designated personnel, a statement of the reason for the request and evidence (such as newspaper articles or other media) of extraordinary circumstances (i.e. a natural disaster). CMS will then respond to the request via email.

Measures Under Consideration for SNF QRP:

CMS is requesting feedback on measures under consideration for future implementation, including four concept categories outlined below.

Interoperability – includes approaches to assessing interoperability in the SNF setting such as measures that address or evaluate the level of readiness for interoperable data exchange, or measures that evaluate the ability of data systems to securely share information across the spectrum of care.
Well-Being – CMS defines well-being as a comprehensive approach to disease prevention and health promotion as it integrates physical and mental health emphasizing preventative care to proactively address potential health issues. Feedback is being sought on tools and measures that assess overall health, happiness, and satisfaction in life that could include aspects of emotional well-being, social connections, purpose, fulfillment, and self-care work.
Nutrition – includes an assessment of an individual’s nutritional status which can include practices designed to promote healthy eating habits and ensuring they receive the necessary nutrients as well as other aspects of health that support nutritional status such as physical activity and sleep.
Delirium – which is often under-detected and leads to negative health outcomes like frailty, cognitive impairment, and functional decline as well as increased risks of rehospitalization, poor functional recovery outcomes, and higher 6-month mortality rate. CMS is seeking feedback on the applicability of measures that evaluate for sudden, serious change in a person’s mental state or altered state of consciousness that may be associated with underlying symptoms or conditions.

Additionally, CMS is requesting feedback on the SNF QRP reporting timeframe which is currently at 4.5 months for data submission. CMS would like to revise it to 45 days to provide the public reporting of data in a more timely manner to help consumers use more recent data to guide their decisions. Specifically, CMS is seeking the following information:

How the potential change can improve timeliness and actionability of SNF QRP quality measures?
How the potential change can improve public display of quality information?
How the potential change can impact SNF workflows or require updates to systems?

CMS is also seeking feedback on the advancement of digital quality measure (dQM) transition to gather broad public input on the dQM transition in SNFs. CMS notes that their objective is to explore how SNFs typically integrate technologies with varying complexity into existing systems and how it affects workflows as well as challenges and/or opportunities that arise during integration to determine the support needed to complete and submit quality data in ways that protect and enhance care delivery.

SNF VBP:

The proposed rule includes the following revisions to the SNF Value Based Purchasing (VBP) program:

Removal of the health equity adjustment from the program scoring methodology. CMS notes that this will aid SNFs in improving their quality of care for all residents and not just those that are dually eligible.
Estimated performance standards for the FY 2028 and FY 2029 VBP program are included in a table located on page 67 & 68 of the proposed rule.
Adoption of a SNF VBP Reconsideration Process beginning with the FY 2027 VBP year that would be an additional appeal process available to SNFs beyond the existing Phase One and Two review and correction process which would align with other quality programs to create a familiar policy experience for providers across CMS quality programs.

Upcoming COE-NF Trainings

The Center of Excellence for Behavioral Health in Nursing Facilities (COE-NF) is offering these upcoming opportunities for you or your staff to receive behavioral and mental health trainings:

Building a Better Suicide Risk Assessment: The Nuts and Bolts of the Columbia Protocol C-SSRS April 23, from 1-2 p.m. CT
Mental Health First Aid (MHFA) – Registration is limited so please only register if you can attend. April 25, from 10 a.m. – 3:30 p.m. CT

HUD Sets 2025 Income Limits for Housing Assistance

The Department of Housing and Urban Development (HUD) released the official 2025 HUD median family income limits, effective April 1. HUD sets income limits every year that determine eligibility for assisted housing programs, including project-based Section 8 and 202, as well as for Public Housing and Housing Choice Vouchers. The limits are based on Median Family Income estimates and Fair Market Rent area definitions for counties and metropolitan areas. The most important statutory provisions relating to income limits are “extremely low-income family” which is defined as very-low income family whose income does not exceed the higher of the poverty guidelines or 30% of the median family income for the area; “very low-income family”, which is defined as low-income families whose incomes do not exceed 50% of the median family income for the area; and “low-income family”, which is defined as those families whose incomes do not exceed 80% of the median family income for the area. Income limits are also adjusted based on family size. Revised income limits do not impact the eligibility of in-place residents, but certain HUD-assisted properties must use the new limits with new move-ins (and initial certifications) of residents, effective April 1, 2025. HUD also develops Multifamily Tax Subsidy Project income limits that determine eligibility for Low Income Housing Tax Credit – financed properties.

CMS Releases Updated List of Unacceptable Hospice Principal Diagnosis Codes

On March 13, the Centers for Medicare & Medicaid Services (CMS) issued a Change Request (CR 13882) which provides an updated list of unacceptable principal diagnosis codes under the hospice benefit. The Claims Processing Manual is also updated to provide guidance on non-reportable principal diagnosis codes and provides clarification of liability claims denials during a hospice election. Specifically, the CR discusses the responsibility and the liability related to missing GW, GV, or 07 modifiers for Medicare-certified providers. CMS noted “It is the responsibility of all Medicare-certified providers to check the Medicare status of each Medicare beneficiary when rendering and billing for services, a claim missing the GW or GV modifier or condition code 07 would be denied as provider liability.” The effective date of the CR is April 1, 2025 – for claims received on or after April 1, 2025, unless otherwise specified, the effective date is the date of service. Any claims submitted with these codes will be returned to the provider with claims edits for non-reportable hospice diagnosis code. Providers will no longer receive edits with reason code 20727 but instead will receive an IOCE edit.

Ask the Expert

A number of member questions come in daily to the association. In this article we will feature unique or recent questions of interest to members.

Q: How do we report an incident in the LLCS Portal?

A: This is a common question from members. On the LLCS Portal task bar, select “Incidents” and on the right side there will be a button to “File an Incident”. If you are unable to locate this button, please email the help desk at DPH.LLCS@illinois.gov. Here is a screenshot of where to locate the button.

If you are unable to report an incident via the LLCS Portal, you are able to submit them to your IDPH Regional Office.

Have a question? Email yours now.